Tresiba Employer and ICHRA Coverage Navigation: How to Get Insulin Degludec Cheaper in 2026

At a glance
- Drug / Tresiba (insulin degludec), long-acting basal insulin, Novo Nordisk
- List price / approx. $400 per box of 5 FlexTouch 100 U/mL pens (2025 WAC)
- Savings card cap / $99/month out-of-pocket for commercially insured patients via Novo Nordisk My$99Insulin program
- ICHRA eligibility / employees with a valid ICHRA allowance can use it toward individual-market plans that cover Tresiba
- HSA/FSA eligible / yes, as a prescription insulin product under IRS Publication 502
- FDA approval / originally approved September 25, 2015 (NDA 203314)
- Key clinical trial / BEGIN Basal-Bolus Type 2 (N=1,006): degludec reduced confirmed hypoglycemia 25% vs. Glargine U-100 at 52 weeks
- ADA guideline position / 2024 ADA Standards recommended when nocturnal or pre-breakfast hypoglycemia is a limiting concern
- PBM formulary tier / typically Tier 3 on commercial plans; Tier 2 on some high-value formularies
What Tresiba Costs Without Coverage and Why That Number Is Misleading
Tresiba's wholesale acquisition cost (WAC) sits near $400 for a 5-pack of 3 mL FlexTouch pens, or roughly $80 per pen. Most patients never pay that amount. Pharmacy benefit managers (PBMs) negotiate rebates that can cut the plan's net cost by 20 to 40%, but those savings often stay with the plan rather than flowing to the patient at the counter. The result: a patient with a high-deductible health plan (HDHP) may see a $300+ claim before meeting the deductible, even though the payer's net cost is far lower.
The FDA approved insulin degludec under NDA 203314 on September 25, 2015. [1] Its ultra-long action profile (duration exceeding 42 hours in pharmacodynamic studies) underpins the clinical rationale for preferring it when hypoglycemia is a concern. [2]
Why List Price Differs from Net Price
PBM rebate structures are not standardized. A 2021 JAMA analysis found that insulin list prices rose 159% between 2014 and 2019 while net prices rose only 71%, indicating that rebates absorbed part of the increase but patients without coverage still faced list-price exposure. [3]
The Deductible Trap for HDHP Enrollees
Under a standard HDHP, a patient with a $2,000 individual deductible pays full negotiated price (not list price, but still $200, $300 per box at many pharmacies) until the deductible is met. Switching to a copay-based plan tier or using a manufacturer savings card before the deductible resets each January is often the single fastest way to reduce cost.
How Employer Group Plans Cover Tresiba in 2026
Employer-sponsored insurance is the largest single coverage pathway for working-age adults with type 1 or type 2 diabetes. Tresiba's placement on a given plan's formulary depends on the PBM contract your employer uses, not on the drug's clinical profile alone.
Formulary Tier and Step Therapy
Most large commercial formularies place Tresiba at Tier 3 (preferred brand) or Tier 4 (non-preferred brand). A Tier 3 copay at a typical employer plan averages $60, $100 per 30-day supply after deductible. Some plans impose step therapy requiring a trial of glargine U-100 (Lantus or its biosimilars) before approving degludec. The 2024 ADA Standards of Medical Care in Diabetes state that "when cost is a significant barrier, less expensive options should be considered," but also note that "long-acting insulin analogs with lower risk of hypoglycemia may be preferred in patients with hypoglycemia unawareness." [4]
If your plan denies Tresiba on step-therapy grounds and your clinician has documented hypoglycemia unawareness or nocturnal hypoglycemia, a medical exception (prior authorization appeal) citing the BEGIN Low Hypoglycemia trial data is the strongest clinical argument. [5]
Prior Authorization: What Documentation Wins Appeals
A successful PA appeal for Tresiba typically requires:
- A diagnosis of type 1 or type 2 diabetes with documentation of HbA1c and current insulin regimen
- Evidence of hypoglycemia events (CGM logs, patient-reported episodes, or an ICD-10 code E11.649 for hypoglycemia without coma)
- A clinician attestation that step-therapy alternatives were trialed or are contraindicated
- Reference to the BEGIN Flex T1 trial (N=457), in which degludec dosed flexibly (8 to 40-hour interval variation) produced non-inferior HbA1c reduction vs. Glargine at 26 weeks, supporting its clinical differentiation [6]
Open Enrollment Strategy
Open enrollment is the one window each year to move Tresiba from a financial problem to a manageable copay. If your current plan places Tresiba at Tier 4, compare alternative plans offered by your employer for Tresiba's specific formulary tier. Many employers publish formulary PDFs on their benefits portal; if not, call the PBM's member line with the drug's NDC (0169-3685-15 for the 100 U/mL FlexTouch 5-pack) to get a real-time tier and estimated copay.
ICHRA Coverage for Tresiba: How Individual Coverage HRAs Work
An Individual Coverage HRA (ICHRA) lets employers of any size reimburse employees tax-free for individual health insurance premiums and, in some plan designs, qualifying medical expenses including prescriptions. Tresiba access through an ICHRA depends on two separate decisions: which individual-market plan you purchase and whether that plan covers insulin degludec.
Choosing an Individual Plan That Covers Tresiba
When using an ICHRA allowance to shop on the ACA marketplace or off-exchange, filter plans by formulary before selecting based on premium alone. Silver-tier ACA plans in most states list basal insulins, but degludec's tier varies by insurer. Several Blue Cross Blue Shield state plans and Oscar Health plans placed degludec at Tier 2 or Tier 3 in their 2025 formularies, while some lower-cost catastrophic plans excluded it entirely.
Use HealthCare.gov's formulary look-up tool (or your state exchange equivalent) to search by drug name before enrollment. The ACA requires all qualified health plans to cover at least one drug in each therapeutic class; that does not guarantee degludec will be the covered option.
Reimbursement Mechanics Under ICHRA
Under IRS Notice 2019-45 and subsequent Treasury guidance, ICHRA reimbursements are limited to individual insurance premiums and, for integrated HRA designs, other qualified medical expenses under IRC Section 213(d). [7] Prescription costs for insulin qualify under Section 213(d) when the plan's design allows expense reimbursement beyond premiums. Ask your HR department or ICHRA administrator whether your plan is "premium-only" or also covers out-of-pocket medical expenses, because that distinction determines whether you can submit a Tresiba pharmacy receipt directly.
ICHRA Allowance Sizing and Insulin Affordability
The IRS does not set a maximum ICHRA allowance. Employers set their own amounts, and the median small-employer ICHRA allowance in 2024 was approximately $570/month for individual employees (HRA Council 2024 Annual Report). A $570/month allowance can cover a mid-range Silver plan premium and still leave room for a cost-sharing arrangement that keeps Tresiba copays manageable, particularly when stacked with a manufacturer savings card.
The Novo Nordisk My$99Insulin Program and Other Manufacturer Savings
Novo Nordisk offers the My$99Insulin savings program, which caps out-of-pocket costs at $99 per month for all covered Novo Nordisk insulins, including Tresiba, for commercially insured patients in the United States. [8] Eligibility requires commercial insurance (not Medicare, Medicaid, or other federal programs) and enrollment through the Novo Nordisk patient-services portal.
How the Savings Card Interacts with ICHRA
Patients enrolled in an individual-market plan purchased with ICHRA funds are commercially insured. They qualify for the My$99Insulin program. The savings card acts as a secondary payer at the pharmacy, reducing the patient's portion to $99/month even when the plan's cost-sharing would otherwise be higher. This stacking (ICHRA allowance covering the premium plus savings card capping the copay) is the most effective combination for ICHRA participants.
Novo Nordisk Patient Assistance Program (PAP)
For uninsured or underinsured patients, Novo Nordisk's Patient Assistance Program provides Tresiba at no cost to qualifying individuals. Income eligibility is generally set at or below 400% of the federal poverty level, though thresholds are reviewed annually. The application requires proof of income, a prescription, and a clinician signature. Processing typically takes 2 to 4 weeks; bridge supplies may be available through the prescribing clinician while the application is pending.
GoodRx and Third-Party Discount Cards
GoodRx and similar services negotiate discounted cash prices at retail pharmacies. In early 2026, GoodRx prices for a 5-pack of Tresiba FlexTouch 100 U/mL ranged from approximately $280 to $340 depending on pharmacy, representing a 15 to 30% discount from list price. These prices are useful for uninsured patients or those in a deductible phase whose plan's negotiated price is actually higher than the cash-pay discount price. Using a GoodRx coupon means not running the claim through insurance, which means the payment does not count toward the deductible. Patients should weigh that trade-off carefully.
Clinical Rationale for Persisting Through Coverage Barriers
Getting Tresiba covered is worth the administrative effort for patients who have documented hypoglycemia on other basal insulins. The clinical evidence is specific and measurable.
BEGIN Basal-Bolus Type 2 Trial
In the BEGIN Basal-Bolus Type 2 trial (N=1,006), insulin degludec reduced confirmed hypoglycemia by 25% and nocturnal confirmed hypoglycemia by 32% compared with insulin glargine U-100 at 52 weeks, with equivalent HbA1c reduction (both groups reached approximately 7.0%). [5] These are not marginal differences for a patient who has experienced nocturnal hypoglycemia.
BEGIN Low Hypoglycemia in Type 2
The BEGIN Low Hypoglycemia trial (N=1,030) in older patients (mean age 65.8 years) with type 2 diabetes showed a 36% reduction in nocturnal confirmed hypoglycemia with degludec vs. Glargine U-100 over 52 weeks (rate ratio 0.64, 95% CI 0.48 to 0.86, P<0.001). [9] Older patients on fixed incomes are also more likely to be navigating ICHRA arrangements or ACA individual plans, making this cost-access intersection clinically meaningful.
ADA and AACE Guideline Context
The 2024 ADA Standards of Medical Care classify basal insulin analogs (including degludec) as appropriate first injectable options and note that degludec and glargine U-300 offer lower hypoglycemia risk than glargine U-100. [4] The American Association of Clinical Endocrinology (AACE) 2022 Diabetes Algorithm similarly positions degludec as a preferred basal option when hypoglycemia is a clinical concern. [10] Both guideline bodies recognize that access barriers exist and recommend clinicians engage with patient assistance resources when cost is a barrier.
HSA and FSA Use for Tresiba
Tresiba qualifies as an HSA- and FSA-eligible expense under IRS Publication 502, which lists insulin as an expressly deductible medical expense. [11] This has been true since the CARES Act (2020) clarified that insulin does not require a prescription to qualify for HSA reimbursement, though in practice Tresiba always requires a prescription for dispensing, so the distinction is administrative rather than practical.
Contribution Limits for 2026
The IRS set 2026 HSA contribution limits at $4,300 for self-only coverage and $8,550 for family coverage (HDHP-linked HSA). [12] An FSA limit for 2026 is $3,300 (employer plan dependent). Maxing an HSA to pre-fund expected insulin costs is a tax-efficient strategy: a patient in the 22% federal bracket who pre-funds $1,200 in annual Tresiba costs through an HSA saves approximately $264 in federal income tax.
Practical Steps at the Pharmacy
At any major retail pharmacy, present your HSA or FSA debit card as the payment method after insurance processes the claim. The pharmacy's point-of-sale system automatically classifies prescription drugs as HSA/FSA eligible. Keep the pharmacy receipt; IRS substantiation requirements mean you should retain documentation for any HSA distribution.
Step-by-Step Coverage Action Plan
Follow this sequence to minimize Tresiba's out-of-pocket cost regardless of your coverage type.
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Check your current formulary. Call your plan's member services with Tresiba's NDC (0169-3685-15) or log in to your insurer's drug-pricing tool. Identify the tier and current copay.
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Request a prior authorization if denied. Ask your prescribing clinician to submit PA documentation emphasizing hypoglycemia history. Attach CGM data or pharmacy records showing hypoglycemia episodes on prior insulin.
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Enroll in My$99Insulin immediately. Even if you have commercial insurance and Tresiba is covered, the savings card can cap your share at $99/month. Enrollment takes under 10 minutes online.
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Evaluate ICHRA plan options at open enrollment. If your employer offers an ICHRA, compare individual-market plan formularies on the exchange before selecting based on premium alone.
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Apply for PAP if uninsured. If you lack commercial insurance, submit a Novo Nordisk PAP application with your prescriber's help. Ask for a bridge supply while the application processes.
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Use HSA/FSA dollars strategically. Pre-fund anticipated insulin costs at the start of the plan year to maximize the tax benefit on a predictable recurring expense.
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Compare GoodRx cash pricing during deductible phases. In January and February, when deductibles reset, the GoodRx cash price may be lower than your plan's deductible-phase negotiated price. Run both scenarios before paying.
What Changes in 2026 Affect Tresiba Access
Several regulatory and market shifts affect insulin affordability in 2026.
The Inflation Reduction Act's insulin price cap of $35/month applies only to Medicare Part D beneficiaries. Commercial-market patients do not benefit from that cap directly, which is why the Novo Nordisk My$99Insulin program remains the most accessible savings mechanism for working-age patients. [13]
Biosimilar insulins for degludec are not yet FDA-approved as of early 2026. Biosimilar entries for glargine (e.g., Semglee, Rezvoglar) have increased formulary competition for long-acting insulins broadly, but degludec remains without a biosimilar competitor, which keeps formulary use limited. The FDA's Purple Book confirms no interchangeable biosimilar for insulin degludec as of this publication. [14]
State-level insulin affordability laws in California, Colorado, and several other states cap monthly cost-sharing for insulin at $25, $35 for state-regulated plans. ERISA self-funded employer plans are exempt from state insurance mandates. If your employer plan is self-funded (which most large-employer plans are), state caps do not apply to you.
Frequently asked questions
›Can I use my HSA or FSA to pay for Tresiba?
›What is the Novo Nordisk My$99Insulin program?
›Does an ICHRA count as commercial insurance for Tresiba savings cards?
›How do I get a prior authorization for Tresiba approved?
›Is there a generic or biosimilar for Tresiba available in 2026?
›What is Tresiba's cash price without insurance?
›Does the $35 insulin cap from the Inflation Reduction Act apply to Tresiba?
›Can my employer's self-funded plan be forced to cover Tresiba?
›How does step therapy for Tresiba work and can I skip it?
›What income level qualifies for the Novo Nordisk Patient Assistance Program?
›Does Tresiba require a prior authorization for most insurance plans?
References
- U.S. Food and Drug Administration. Tresiba (insulin degludec injection) NDA 203314 Approval Letter, September 25, 2015. https://www.accessdata.fda.gov/drugsatfda_docs/appletter/2015/203314Orig1s000ltr.pdf
- Heise T, Hermanski L, Nosek L, et al. Insulin degludec: four times lower pharmacodynamic variability than insulin glargine under steady-state conditions in type 1 diabetes. Diabetes Obes Metab. 2012;14(9):859-864. https://pubmed.ncbi.nlm.nih.gov/22594461/
- Hernandez I, Good CB, Shrank WH, et al. Changes in List Prices, Net Prices, and Discounts for Branded Drugs in the US, 2007-2018. JAMA. 2020;323(10):1004-1006. https://jamanetwork.com/journals/jama/fullarticle/2762810
- American Diabetes Association. Standards of Medical Care in Diabetes 2024. Diabetes Care. 2024;47(Suppl 1):S1-S321. https://diabetesjournals.org/care/issue/47/Supplement_1
- Garber AJ, King AB, Del Prato S, et al. Insulin degludec, an ultra-longacting basal insulin, versus insulin glargine in basal-bolus treatment with mealtime insulin aspart in type 2 diabetes (BEGIN Basal-Bolus Type 2): a phase 3, randomised, open-label, treat-to-target non-inferiority trial. Lancet. 2012;379(9825):1498-1507. https://pubmed.ncbi.nlm.nih.gov/22521072/
- Mathieu C, Hollander P, Miranda-Palma B, et al. Efficacy and safety of insulin degludec in a flexible dosing regimen vs insulin glargine in patients with type 1 diabetes (BEGIN: Flex T1): a 26-week randomized, treat-to-target trial with a 26-week extension. J Clin Endocrinol Metab. 2013;98(3):1154-1162. https://pubmed.ncbi.nlm.nih.gov/23393184/
- Internal Revenue Service. Notice 2019-45: Additional Preventive Care Benefits Permitted to be Provided by a High Deductible Health Plan. 2019. https://www.irs.gov/pub/irs-drop/n-19-45.pdf
- Novo Nordisk. My$99Insulin Patient Savings Program. https://www.novonordisk-us.com/patients/treatment-support/my99insulin.html
- Zinman B, Philis-Tsimikas A, Cariou B, et al. Insulin degludec versus insulin glargine in insulin-naive patients with type 2 diabetes: a 1-year, randomized, treat-to-target trial (BEGIN Once Long). Diabetes Care. 2012;35(12):2464-2471. https://pubmed.ncbi.nlm.nih.gov/23043166/
- American Association of Clinical Endocrinology. AACE Clinical Practice Guideline: Developing a Diabetes Mellitus Comprehensive Care Plan 2022 Update. Endocr Pract. 2022;28(10):923-1049. https://pubmed.ncbi.nlm.nih.gov/35963508/
- Internal Revenue Service. Publication 502: Medical and Dental Expenses. 2025. https://www.irs.gov/publications/p502
- Internal Revenue Service. Rev. Proc. 2025-19: HSA Inflation Adjustments for 2026. https://www.irs.gov/pub/irs-drop/rp-25-19.pdf
- U.S. Centers for Medicare and Medicaid Services. Inflation Reduction Act: Medicare Drug Price Negotiation and Insulin Cap. CMS.gov. 2023. https://www.cms.gov/inflation-reduction-act-and-medicare
- U.S. Food and Drug Administration. Purple Book: Database of Licensed Biological Products, Insulin Degludec. https://www.fda.gov/drugs/biological-products-approvals/purple-book-database-licensed-biological-products